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On April 22, 1992, respondent mailed to petitioner a notice
of deficiency determining a deficiency of $15,494 in petitioner’s
Federal income tax for 1989 and additions to tax under sections
6651(a)(1) and 6654(a). Respondent mailed the notice to
petitioner at the N. Central address.
By letter dated June 1, 1992, petitioner wrote to respondent
acknowledging receipt of the above-described notice of deficiency
and again citing the UCC for the proposition that “the Notice of
Deficiency, dated April 22, 1992, a presentment on your behalf,
is dishonored.” Petitioner failed to file a petition with the
Court challenging the notice of deficiency for 1989.
2. 1990 Through 1992
On February 2, 1995, respondent issued to petitioner (at the
N. Central address) a so-called 30-day letter with respect to
petitioner’s tax liabilities for 1990 through 1992.
By letter dated February 17, 1995, John B. Kotmair, Jr. (Mr.
Kotmair) of Westminster, Maryland, wrote to respondent
challenging petitioner’s tax liability for the taxable years 1990
through 1992.2 Mr. Kotmair’s letter listed petitioner’s address
as #43 Richardson Heights Village, Richardson, Texas 75080 (the
Richardson Heights address). Mr. Kotmair’s letter included as an
attachment a copy of the above-described 30-day letter dated
2 The gist of Mr. Kotmair’s letter was that respondent
lacked authority to examine the taxable years 1990 through 1992
because petitioner did not file income tax returns for those
years.
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Last modified: May 25, 2011